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Privacy & Disclosure Policy

Shanghai Cross Ocean Everfast Property Development Co. Ltd. The PuLi Hotel and Spa (hereinafter referred to as “our hotel” or “we”) are aware of the importance of personal information and will do all we can to protect your personal information. Our privacy & disclosure policy explains what data is collected from hotel guests, visitors to our hotel website and WeChat official account, as well as how this information is utilised for your best interest. By continuing to browse our hotel website, WeChat official account or using our products and services, you have understood and agreed to our privacy & disclosure policy (hereinafter referred to as “this privacy & disclosure policy”), allowing us to collect, use and disclose your personal information.

This privacy & disclosure policy will help you understand the following content:

1. How we collect and use your personal information;
2. How we use the Cookies function;
3. How we share or disclose your personal information;
4. How we protect your personal information;
5. Your rights;
6. How we manage children’s personal information;
7. How we update this privacy & disclosure policy;
8. How to contact us.

1. How we collect and use your personal information:

Personal information refers to information recorded electronically or by other means that can identify a person or reflect the activity and behaviour of a particular person, either alone or in combination with other information. The personal information we manage include:

  • Basic information: Including but not limited to name, gender, age, photo, personal identification number or passport details.
  • Contact information: Including but not limited to address, postcode, email address and telephone number.
  • Financial information: Including but not limited to credit card details, method of payment, bank information and transaction history.
  • Technical information: Including but not limited to information collected from the devices you use while interacting with us (including unique identifiers, hardware models, operating systems and versions, as well as other information such as mobile network information and location when using mobile devices).
  • Information related to your needs and requirements: Including but not limited to your preferences, service related information and health information.

When managing our technical tools and providing services, we will collect your personal information; these tools and services include member registration forms, email communications sent and received to/by us and others. In addition, we will collect information provided by you or information gained through the following interactions with you:

  • When you provide your personal information or access information stored while on our premises, website or WeChat official account.
  • When you make a booking or purchase while on our premises or through our website.
  • When you communicate with us over the telephone or online.
  • When you make a transaction with us.

We also collect your personal information from our business partners, public sources and other sources.

We collect, manage and use your personal information only for the purposes set out in this privacy & disclosure policy:

  • To browse our hotel website and WeChat official account, as well as to register and become our member.
  • To share hotel information, personalised recommendations or promotional materials.
  • To ease communication between our hotel and you.
  • To better provide products and services to you at the time of payment, settlement and delivery of goods.
  • To conduct internal audits, data analysis and research to improve our products and services.
  • To meet legal and regulatory requirements.

We will seek your consent in advance, should we use your personal information for purposes not covered in this privacy & disclosure policy.

2. How we use the Cookies function:

To maintain our website regular performance, we store Cookies in your computer or portable device. Cookies may contain keywords, numbers, site names, and characters. Cookies allow websites to store your preferences or items in your shopping cart.

We do not use Cookies for any purpose other than those stated in this privacy & disclosure policy. You can manage or delete Cookies based on your preferences. For more information, please refer to http://www.allaboutcookies.org/. You can clear all Cookies stored in your computer, most web browsers have the ability to block Cookies. However, if you block Cookies, you may not be able to use our website’s full function.

3. How we share or disclose your personal information:

We may disclose your personal information to third parties for the following purposes:

  • We will disclose your personal information to third parties after receiving your consent.
  • We may disclose your personal information in accordance with laws or government regulations, or as mandated by government authorities.
  • We may disclose your personal information to our business affiliates and will adhere to the purposes stated in this privacy & disclosure policy.
  • For the purposes stated in this policy, some of our services will be provided by third parties, we may share your personal information to provide better customer service and user experience. For example, if you consent to receiving advertising by mail, we will share your personal information with the postal service provider to arrange mailing activities.

4. How we protect your personal information:

We use a variety of safety measures to protect the personal information you provide to us to prevent unauthorised access, unauthorised public disclosure, unauthorised use, modification, damage or loss of data. We will place appropriate control mechanisms to ensure that only authorised personnel have access to personal information. In principle, the personal information we obtain in the People’s Republic of China will remain within the territory of the People’s Republic of China.

The personal information you provide to us will be stored in our database and/or our service providers’ databases, protected by physical and electronic measures, firewalls and other necessary security measures. However, such security measures do not completely prevent the loss, misuse or alteration of personal information, and to the fullest extent permitted by law, we are not responsible for any damage or compensation resulting from such incidents.

5. Your rights:

In accordance with China’s relevant laws, regulations, standards as well as that of other countries and regions, we guarantee your rights to access, update, delete, restrict access or object to the processing of your personal information.

You have the rights to access, update, delete, restrict access or object to the processing of your personal information, except for those required by laws and regulations. If you wish to access, update or delete your personal information and payment method in your personal account, change your password, add security information or change the scope of the authorisation you have provided to us, you may do so through our hotel website or WeChat official account.

If you are unable to complete the above operation, you may send an email to information@thepuli.com for assistance. For safety purposes, you may need to provide a written request or provide proof of identity. We may ask you to verify your identity prior to processing your request.

For reasonable requests, we do not charge any fee, however for multiple requests exceeding reasonable limits, we will apply a certain fee according to the situation. For those who require unreasonable changes, require extensive technical support (for example requiring the need to develop new systems or fundamentally modify the current practice), bring to others risks and unreasonable reasons (for example unrealistic requests involving backup tapes and storage), requests such as these may be rejected.

In the cases stated below, we will not be able to respond to your requests as required by laws and regulations:

  • Cases relating to the country’s security and national defense security.
  • Cases relating to public safety, public health and public interest.
  • Cases relating to criminal investigation, prosecution, trial and enforcement of judgments.
  • Cases where there is sufficient evidence that you have malicious intents or are abusing rights.
  • Cases where responding to your requests will result in serious damage to you or other person or organization.
  • Cases involving trade secrets and statutory confidentiality agreements.
  • Cases where it is proven that it is impossible to provide such information or will incur a significant cost.
  • Information you already posses.

6. How we manage children’s personal information:

Our products, services and website are intended for adults and should not be used by children without parental or guardian supervision.

Although there are different definitions of children according to local laws and customs, we classify any person under 16 years of age (or the minimum age as required by local law, whichever age is higher) as a child.

7. How we update this privacy & disclosure policy:

Our privacy & disclosure policy might change. We will indicate changes at this page whenever any revisions are made to the privacy & disclosure policy.

8. How to contact us:

Should you have any enquiries regarding this privacy policy disclosure, you may contact us by emailing information@thepuli.com.

Effective commencement date: 12 October 2018

Should there be any discrepancies between Chinese version and other language version of the privacy & disclosure policy, the Chinese version prevails.